A formula that allocates resources including staff positions and non-personnel resources directly to schools, and that ensures each Title I school gets all of the funding it is entitled to, as measured by the sum of (1) the number of personnel in the school multiplied by the district’s average salaries for each staff category, and (2) the number of students in the school multiplied by the district’s average per-pupil expenditures for non-personnel resources.

In other words, districts could be forced to move staff from one building to another because of salary levels in buildings.

If you are interested in sending a comment to US DOE, click here. The comment period closes on November 7, 2016 at 11:59 pm.

CCSSO Executive Director Chris Minnich said, “It’s clear that the Department has listened and tried to incorporate feedback in this proposed rule. However, we are disappointed with the language we have seen in the proposed regulation. Schools would be forced to move resources around at the last minute each year to try to meet a federal mandate, rather than doing what is in the best interest of students. The Every Student Succeeds Act gives states more flexibility so we can create opportunities for all kids, and this proposed rule is not consistent with the law. Unfortunately, in the Department’s effort to ensure resources go to the students who need it the most, they have created a situation where the reverse is likely to occur in many places. We look forward to helping get this right before the rule becomes final.”